BD Speeches

"Failure to have adequate written policies and procedures and failure to have adequate supervisory and compliance oversight may indicate recurring issues in complying with Regulation ...

While CAT has been firmly established as an operational regulatory reporting system, 2021 will be another important year of milestones for CAT, with transaction reporting, ...

I am not convinced, however, that these protections are adequate given the potentially high stakes of any conditions or restrictions for the viability of a ...

"It should not provide a grace period for compliance with clear violations of law -- especially violations that put investor funds directly at risk.  Here, ...

The net result of these changes would be a more secure CAT, operating without sensitive PII

I would have preferred the bolder step of confronting the CAT’s real and serious liberty implications

These changes, however, do not address the deeper problem with the CAT, namely the significant costs that a comprehensive surveillance tool of this type presents ...

Equity Market Surveillance Today and the Path Ahead

Testimony Before the Subcommittee on Capital Markets, Securities, and Investment Financial Services Committee

Remarks at IRI Government, Legal and Regulatory Conference